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Steve MacArthur

Steve MacArthur is a safety consultant based in Bridgewater, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

Gaining some Perspectives on The Doors of Perception

I’m going to guess that you all out in the audience do not necessarily place The Joint Commission’s Perspectives periodical on your list of must-reads, but for the May and June 2012 issues (and who knows beyond that), you really owe it to yourself to grab a copy and prepare for some hard-hitting door and barrier conversation with our esteemed colleague, one Mr. George Mills, Director of the Engineering Department at The Joint Commission.

At any rate, I think we can point to an increasing level of frustration on the part of the various and sundry regulatory agencies (and us, don’t forget us) relative to the number of findings in the life safety (LS) chapter and the omnipresence of these issues in the most frequently cited standards during surveys. How do we make this go away? The answer to that question, interestingly enough, is adopting a risk-based strategy for the ongoing inspection and maintenance of whatever building component is in play – this month its doors. [more]

Taking care of business

Earlier today, I was conducting an EC/EM interview session with a very participative group and I was complimenting them on their ability to speak to improvement efforts in areas that are not necessarily in their scope of practice. Now, my experience has been that the folks most familiar/expert with the EC function being discussed tend to dominate the conversation (sometimes in a good way, sometimes not) and I thought it was cool that these folks were so familiar with what others in the group felt was important. To my compliment, the observation was made (and I thought this was absolutely the grandest definition of what a high-performance team can achieve) that they mind each other’s business. In that simple turn of phrase (not an exact quote – sometimes paraphrase is the best I can do), the whole concept of what the EC team can embrace and accomplish was crystallized: It’s not about what may or may not be “somebody else’s job” (or “not my job”); it’s actually using the team concept to make and sustain improvements. In the old days we used to call that type of organizational behavior “silos,” which is OK if you’re storing grains and such, but when the goal is organizational improvement, we want to be more like a snack mix with all sorts of nuts and fibrous bits.

And please keep in mind, it’s not necessarily about never having any issues to correct. As long as there are human beings in the mix, there will be corrections to make – be assured of that. But if you can harness the power of a group of committed individuals who accept responsibility, hold each other accountable, and care enough to “mind each other’s business,” you can accomplish so much. There’ll always be stuff to do, but think about the power of getting stuff done.

Brings a smile to my face – how ‘bout you?

Dry your eyes – but don’t dry those wipes!

A quick note of interest from the survey world –

A recent survey resulted in a hospital being cited under the Infection Control standards (IC.02.02.01 on low-level disinfection, to be exact). In two instances, someone had the temerity to forget to close the cover on a container of disinfectant wipes. Can you believe such risky behavior still exists in our 24/7 world of infection prevention? It’s true, my friend, it is true!

The finding went on to say that, as the appropriate disinfection of a surface depends on wet contact with the surface being disinfected, leaving the cover open would partially dry out the next wipe, impairing the ability of the wipe to properly disinfect the surface. Now, I suspect that the person to use that next wipe might somehow intuit that the moisture content in the wipe was not quite where it needed to be and maybe, just maybe, go to the lengths of (wait for it) – pulling out an additional wipe (or two, or three). Now my experience has been that sometimes those wipes are not what I would call particularly well-endowed in the moisture department. And  the use instructions for these products usually indicate that you should use as many wipes as it takes to ensure that the surface to be disinfected stays wet long enough for disinfection to occur.

I’ve always been a pretty big fan of the slowly-becoming-less common sense, so I’m not quite sure how we’ll be dealing with this one – thoughts, anyone?

Do you remember? Or even yesterday…

Way back in September of last year, we were chatting about the importance of appropriately managing conditions in the patient environment, primarily the surgical environment. For those wishing for a refresher, you can find that post here. (I talked about how I’ve noticed recent citation in surveys regarding the surgical environment, including the maintenance of temperature and humidity, ensuring appropriate air exchange rates, and making sure that your HVAC systems are appropriately maintaining pressure relationships, etc.)

One of the things I didn’t really cover back then was when you have documented out-of-range values. Could be temperature, could be humidity, could be those pesky air exchanges and/or pressure relationships. The fact of the matter is that we live in an imperfect world and, more often than not, our success comes down to how effectively we manage those imperfections. And that can, and does, come down to how well we’ve prepared staff at the point of care/service to be able to respond to conditions in the environment. But, in order to get there, you have to undertake a collaborative approach, involving your infection preventionist and the folks in the surgical environment.

The management of risk in the environment doesn’t happen because we have (or don’t have) nifty technology at our disposal; it’s because we can work collaboratively in ways that no building automation system or self-regulating HVAC equipment can. This idea has become an increasingly important part of the survey process. We know that more folks are harmed by hospital-acquired infections and other related conditions and I’ve seen it become a fairly significant survey vulnerability. So, let’s start talking about this stuff with the end users and make sure that we’re ahead of the curve on the matters of the care environment.

Panic in Detroit – Panic at the Disco – Panic at the Surgery Center…Fire in the Hole!

I’m presuming (and please don’t attempt to disabuse me of this notion) that you are all dutifully conducting security risk assessments on a regular basis. As you conduct them, I’m sure you find risks of some events that are greater than some other areas. So, I to ask: When you’ve completed your security risk assessment, do you identify specific strategies, including the use of technology, for minimizing those risks to the extent possible? If you’re not including that facet in the risk assessment process, you might want to consider doing so.

Recently, I was looking at a survey report in which an ambulatory surgery center was cited during a TJC survey because they had not installed a panic alarm “at the registrar’s desk in order to obtain immediate assistance in an emergent or hostile situation.” Now, as with so many things that have been popping up during surveys, I don’t disagree with the concept of having panic alarms at those customer service/interaction points where unhappy folks (or folks of any ilk) can experience the need to vent their frustrations, etc. But in that disagreement, I think I’d first be looking at what tools have been provided to staff to actively manage, if not de-escalate, these negative encounters. I would much prefer to avoid having to use a panic alarm by appropriately managing the encounter, much like I would just as soon not “need” to have an emergency eyewash station.

I’m a great believer in the proactive management of risk, but I’m also a great believer in implementing risk management and response strategies that make operational sense. So, the question to the studio audience is: Where have you installed panic alarms and where have you not installed panic alarms, and why? There’s always the risk that some surveyor will disagree with your strategy, but if that strategy was derived through thoughtful analysis of the involved risks, does that not meet the intent of all this?

I like the concept of best practice as much as anyone, but I also recognize that there is a tremendous amount of variability in the safety landscape. Just because something works in one place does not necessarily mean that it will work in all cases—that’s the mystical, magical, and ultimately mythical power of the panacea. One size doesn’t fit all—never has, never will. But if we’re going to be held to that type of an expectation, how does that help anyone? Ok, jumping down from soapbox for now, but rest assured, you’ll see me back up here before too long.

Shock the monkey (part x + y to the 10th power) – here we go again…

OK, so now it appears that we’re going to have to rethink how we schedule preventative maintenance (PM) activities on our critical equipment, particularly if that criticality affects patient health and safety. I believe that we’ve already chatted a bit about the whole clarification of PM frequencies and where CMS stands on the issue (in case you hadn’t noticed, they’re pretty much standing on your head).

In issuing the clarification (and I will freely admit that I missed this at first – check it out at: https://www.cms.gov/Surveycertificationgeninfo/downloads/SCLetter12_07.pdf), the Feds have decided that, in the matter of critical equipment, the frequency will reflect manufacturer recommendations, AND NOTHING ELSE! Let me repeat that: AND NOTHING ELSE!

For example, PM’ing defibrillators on an annual basis (despite what your experience might indicate) is a big freaking no-no! Isn’t that special? Yeah, I thought so, too.

Maybe this isn’t anything to you folks, but I know of at least one hospital that got cited during a recent survey, so when there’s one, there’s usually others (these things almost never happen in isolation). So, if you think you may be taking advantage of logic and common sense approaches to the management of the risks associated with the use of medical equipment, think again (hopefully this won’t shift again, but if history tells us anything.)

Shoo beedoobee – splattered, splattered!

In the never ending discourse on the subject of emergency eyewash stations, I’d like to take a moment to remind folks that it appears that the TJC surveyors have access to the ANSI Emergency Eyewash and Shower Equipment Standards and they have become very diligent in ferreting out (apologies to the ferrets in the audience – I don’t mean to offend) practices that are not consistent with the “recommendations” contained therein. And so, let me say this:

If your organization has chosen to maintain your emergency eyewash stations on a lesser frequency than weekly, then you had best conducted a risk assessment to demonstrate that you are ensuring the same level of safety that you would if your were maintaining them on a weekly basis. Water temperature, water pressures, “cleanness” of the flushing liquid, whether access to the equipment is obstructed – these all need to be considered in the mix, because, and I can tell you this with a great deal of certainty, if you are doing these inspections less than weekly, you will be cited during survey. If you have not conducted the risk assessment to demonstrate that the lesser frequency is appropriate, then you will have to move to the weekly program. (Sort of a “you can pay me now or you can pay me later” kind of deal.) But rest assured that eyewash stations are definitely in the mix, so make like a Boy Scout (do I really need to finish that thought? I didn’t think so…)

By the way, I’ve also caught wind of the invocation of AAMI standards when it comes to the placement of emergency eyewash equipment in the contaminated section of central sterile. (Also, don’t forget to keep those pressure relationships in check. Clean central sterile should never be negative to dirty central sterile). Now I will freely admit that I am not as conversant with the AAMI standards as I am with, say, OSHA standards, and perhaps even the ANSI standards dealing with this stuff. Again, the rhetorical question becomes: How many rocks do we need to turn over before we can safely determine that there isn’t some funky consensus standard lurking in the weeds that is not in strict concurrence with accepted practice? Why can’t these guys just get along…jeez!

She’s a laughing, giggling whirly bird – oh heli!

Interesting development on the survey front in the last couple of weeks. I’m not at all sure what it means, but I thought I would share it with you all, make of it what you will.

During a recent survey in the Sunshine State, a hospital was cited for not having the “recommended (maximum) rotor circumference signage on the pad nor the other recommended signs that are recommended by the FAA” (signs such as “MRI in use,” etc.). Now we could certainly have a good time parsing the whole “recommended signs that are recommended” phraseology, but I keep coming back to that word “recommended.”   How far do we have to go to ensure that we have somehow accounted for every recommendation for every possible risk that we might encounter?. Yeah, beats me, too, but in the interest of furthering the applicable knowledge base, let’s step to the web for some edification:

First I draw your attention to the Advisory Circular issued by the FAA back in 2004. I can’t seem to lay my mitts on anything more contemporary than this, but if you find something more recent, please share.

Now, as we scan the first page of this most comprehensive document, we see a little statement that I think makes the TJC survey citation a little more squishy than I would prefer: “This AC is not mandatory and does not constitute a regulation except when Federal funds are specifically dedicated for heliport construction. “ To me, “not mandatory” sounds like a really big case of the “we don’t have to’s,”  what do you think?

Turning to Chapter 4, Hospital Heliports (this is on page 95 of the document), I will freely admit that there’s a lot of interesting/cool information. (Did you know that the FAA recommends Portland Cement Concrete for ground level facilities—who knew? Do you have Portland Cement Concrete for your ground level facilities? I certainly hope so). Anyway, the chapter describes a lot of important stuff about hazards and markings, including MRI impact, etc.

I’m going to guess that you’ve been having helicopters fly in and out of your airspace on a regular basis, and in all likelihood, some of you are already up to speed on this.  For those of you for whom this might be virgin territory, my advice would be to consult with the folks actually doing the flying and find out what they want to see with your helicopter setup. This would constitute what I euphemistically refer to as a risk assessment. You may have encountered that term once or twice here in Mac’s Safety Space. I can’t imagine that you’d not have heard by now if the pilots using your pad have issues. (I’ve never found them to be shy about safety—nor should they be.) Still, it’s never a bad idea to reach out periodically to make sure that everything is both hunky and dory; it’s really the least we can do.

Update: Link correction for CMS memorandum on LSC

I have been alerted that the link below did not work. I have corrected that link, but I’ll provide it here too:

Click here to directly access the CMS memorandum the changes regarding the Life Safety Code®.

(Ref: S&C-12-21-LSC)

There’s a light, a certain kind of light – and it’s not an oncoming train!

This one has the potential to be the game-changer we’ve been hoping (waiting) for – the emergence of the 2012 edition of the Life Safety Code® as a CMS-sanctioned regulatory standard.

Once you lay your hands on this plucky little document –  the official CMS memorandum – you will see that it appears) to represent a fair degree of flexibility when it comes to, among other things, corridor storage, and the amount of combustible decorations that are allowed. One thing this likely means is that everyone’s going to be inundating NFPA for their own personal copy of the 2012 Life Safety Code® – this is going to become a go-to resource from here on out.

Now, the first thing you will notice is that there’s a lot of mention of nursing homes, and not so much of hospitals, particularly on Page 1. To that end, let me direct you toward the bottom of page 2 of the document (under the section titled “Effective Date”), which specifically indicates that the memorandum and all its components are “in effect for all applicable healthcare facilities such as Hospitals and Nursing Homes.”

The other caveat, at least for the moment, is that it appears that the changes are only “accessible” through the CMS waiver request process, which will, in turn, result in a process in which “each waiver request will have to be evaluated separately in the interest of fire safety and to ensure that the facility has followed all LSC requirements and the equipment has been installed properly by the facility.” I’m not entirely certain whether this would drive anything more than a review of the waiver request, but I’m not entirely certain how they’d be able to ensure compliance with LSC requirements, etc., without eyeballing a facility. That said, there’s a whole heck of a lot of hospitals that would be pursuing this, so maybe there’s a process in place, maybe based on past TJC/DNV/HFAP and/or CMS survey results.

So, what it looks like we have here is some room for stuff in the corridors, including fixed furniture; and the presence of combustible decorations on “walls, doors and ceilings.”

That’s enough yapping from me for the moment; I encourage you to check out the document and let us know what you think. I think it’s very interesting.